The notice of claim demands $12 million from each of the three entities -- the city, county, and state -- but offers a settlement of $12 million total.

The claim from Scottsdale law firm Knapp & Roberts accuses the entities of various "negligent acts and omissions that caused of contributed to the death of Grant McKee and the 18 other members of Granite Mountain Interagency Hotshot Crew."

It points to violations of wildfire-safety guidelines, and the "almost useless" report on the fire that was released in September, three months after the 19 men died.

At this point, it is apparent that the liable public entities carelessly let the Granite Mountain Hot Shots move into a rugged, brush-filled area where escape from the oncoming fire was impossible. The liable public entities had lost track of the location and direction of movement of the Granite Mountain Hot Shots, had deployed them carelessly, had negligently failed to support them or to coordinate their movements with other assets in the area, had failed to maintain consistent, effective communication with them, had recklessly failed to realize the extreme peril that confronted them, had carelessly failed to provide them with one or more logical and accessible escape routes or areas of refuge, and had negligently failed to deploy aerial assets to assess their peril and drop fire retardant chemicals to help protect them.

The liable public entities carelessly and negligently let Grant McKee and his fellow crewmembers die excruciating deaths. With the use of modern technology and the application of old-fashioned common sense, the death of these fine men was entirely preventable.

In total, there are 19 allegations of negligence outlined in the notice of claim.

In addition to those allegations, the notice of claim also blasts that report released by investigators, which McKee's attorney essentially deems useless for the purposes of fact-finding.

"The Yarnell Hill Fire Report is a whitewash," the notice says. "Its primary goal is to avoid blaming anyone. As a result, an trusting, uninformed person reading the Yarnell Hill Fire Report uncritically would think that the death of 19 men was just bad luck and no one's fault--which is false."

Indeed, the report stated right up front, "The Team found no indication of negligence, reckless actions, or violations of policy or protocol."

Officials with knowledge of the circumstances surrounding the fire laid blame on various things in the weeks leading up to the report, but when it was released, it said everything happened as expected.

The notice of claim also includes a section explaining the "tremendous suffering" of Marcia McKee since her son's death.

"Our last phone conversation was me telling him to be careful and his response was 'What are the odds of me dying in a fire? Think about it Mom,'" Marcia McKee writes. "I told him I loved him and still be careful. He said to me 'I love you too Mom.' That was the last time I'll ever hear my baby call me Mom."

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